INTERNATIONAL WILDUFE COALITION 



April 3, 1991 



Mr. Joseph Uravitch, Chief 



Sanctuaries and Reserves Division 



Office of Ocean and Coastal Resource Management 



National Oceanic and Atmospheric Association 



1825 Connecticut Avenue, NW, Suite 714 



Washington, D.C. 20235 



Dear Mr. Uravitch, 





On behalf of the International Wildlife Coalition, 

 representing a membership of 235,000, I would like to offer 

 the following comments pertaining to the Stellwagen Bank 

 National Marine Sanctuary Draft Environmental Impact 

 Statement/Management Plan. 



Stellwagen Bank exceeds all criteria established by NCAA as 

 an area of special significance and is deserving of National 

 Marine Sanctuary designation. The area is the basis for a 

 rich commercial fishing industry which is important^ 

 culturally, historically and economically. Protection 

 offered by the Sanctuary will ensure that the area s fishing 

 heritage will flourish for generations to come. Stellwagen 

 Bank is also a high use, perhaps critical area for many 

 species of marine mammals, including endangered species such 

 as right, fin and humpback whales. Despite its ecological 

 and economic importance, the Bank is threatened by many 

 current and proposed activities. 



We believe that many of the regulations proposed by NCAA in 

 its Draft Environmental Impact Statement for Stellwagen Bank 

 offer excellent protection for the Bank and its resources. 

 Specifically, we would like to support NCAA's prohibitions 



on 



alteration of or construction on the seabed 



industrial materials development 



installation of pipelines and cables 



the taking of marine reptiles, mammals and seabirds 



the disposal of dredged materials 



1) 

 2) 

 3) 

 4) 

 5) 



J. 



We would particularly like to support NCAA's decision to 

 impose no separate Sanctuary restrictions on commercial 

 fishing activities. 



However, there are also several areas in which we believe 

 that the Sanctuary regulations preferred by NCAA are 

 insufficient to protect the Bank and its resources. 



INTERNATIONAL WILDLIFE COALITION 

 1. No response necessary. 



2. See generic response N. 



3. 



1) The boundary for the proposed sanctuary. We support the 

 adoption of option #3 for the Sanctuary boundary. As 

 boundary #2 is contained wholly within boundary #3, all 

 benefits of the second option also apply to our preferred 

 boundary. There are however, important benefits provided by 

 boundary |3 which are not inherent to boundary »2. NOAA's 

 preferred boundary (#2) fails to take advantage of the 

 potential for an ecosystems approach to management. The 

 boundary of option |3 would form a nearly contiguous link 

 with existing waters protected by the state of 

 Massachusetts. This would provide the type of 

 comprehensive protection and management which is the 

 strength of the Sanctuary program. 



We also believe that NOAA's preferred option (boundary #2) 

 has serious drawbacks associated with the Massachusetts Bay 

 Disposal Site (MBDS) . In an effort to move the MBDS outside 

 of Sanctuary waters, the Envirnmental Protection Agency 

 (EPA) has proposed to shift the location of the site to 

 overlie the existing Industrial Waste Site (IWS) and its 

 1,000's of barrels of radioactive and toxic waste. The 

 original EPA decision to separate the two dump sites was 

 made to allow for the monitoring of the IWS and the possible 

 taking of remedial action at a future date. Placing the 

 MBDS on top of the IWS would make these actions impossible. 



3. See generic responses B.l. and D.l. 



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